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RATLIFF v. C.I.R.

No. 88-1191.

865 F.2d 97 (1989)

Howard RATLIFF and Gloria Ratliff, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided January 6, 1989.

Attorney(s) appearing for the Case

Martin M. Ruken (argued), Stuart D. Kenney, Vedder, Price, Kaufman & Kammholz, Kenneth C. Shepro, Altheimer & Gray, Chicago, Ill., for petitioners-appellants.

Gary R. Allen, Acting Chief, Kenneth L. Greene (argued), Richard Farber, U.S. Dept. of Justice, Tax Div., Appellate Section, Washington, D.C., for respondent-appellee.

Before: MILBURN and NORRIS, Circuit Judges; and SUHRHEINRICH, District Judge .

MILBURN, Circuit Judge.

The present case is but one part of the London option cases pending in the United States Courts of Appeals around the country after the decision of the Tax Court in Glass v. Commissioner, 87 T.C. 1087 (1986). In Glass, the Tax Court consolidated over 1,100 petitions contesting the decision of the Commissioner of Internal Revenue that losses sustained in connection with certain straddle transactions...

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